U.S. Fish and Wildlife Service Releases New Guidance on the Importation of Trophies

[AfricaHunting.com]

U.S. Fish and Wildlife Service Releases New Guidance on the Importation of Trophies

Over the last few months, SCI staff has been working diligently with the U.S. Fish and Wildlife Service (FWS), importers and other members of the regulated community to find a solution to a recent spike in seizures of sport-hunted trophies. On Friday February 24th, the FWS released a memo that clarifies the instructions on tagging and marking leopard, Nile crocodile and African elephant trophies. We commend the FWS for taking a first step to help reverse the incidences of seizures due to paperwork and procedural problems with importation. SCI will continue to work with the FWS to solve importation problems that interfere with trophy importation by many SCI members. The FWS's full memo is attached and SCI strongly encourages our members who are planning on hunting any of these three species to read through the entire memo and to provide a copy to their Professional Hunter, Outfitter and/or Taxidermist or whoever else might be involved in the preparation and exportation of these trophies.

One particular source of trophy importation problems relates to the tags and/or tusk markings required for the importation of CITES Appendix I trophies. In some circumstances the trophy is taken in one year and imported in a different year. In those circumstances, the tags and/or tusk markings must include different information about the quota from which the animal was taken than must appear on the CITES export permit document. The attached memo provides specific information to cover the requirements for these circumstances.

One particularly significant statement in the memo appears in its last line where the FWS explains that, 鉄port-hunted trophies imported into the United States that do not comply with the marking, tagging or CITES document requirements are subject to refusal of entry or seizure. With this sentence, the FWS acknowledges that refusal of entry is a potential strategy that hunter/importers can request to avoid trophy seizures. If and when a hunter/importer is faced with procedural or paperwork deficiencies concerning the importation of the trophy, the hunter/importer may ask for the FWS to refuse entry of the trophy and to return the trophy to the country of export. A refusal of entry is not a means of fixing existing paperwork flaws. Instead it requires the hunter/importer to restart the exportation process with new exportation and importation documents. While it may be expensive to ship a trophy back to Africa and to seek new documentation, in many cases this cost and effort will be far more reasonable than losing a trophy to seizure. It is important to understand that the FWS is unlikely to elect to refuse entry unless the hunter/importer specifically asks for that option. For this reason, SCI strongly recommends that hunter/importers who are facing a possible seizure ask that their trophy be refused entry rather than seized. Hunters/Importers should retain the attached FWS memo and show it to the FWS border official if any question arises.

If you have any questions please contact Bill McGrath wmcgrath@safariclub.org or the U.S. Fish and Wildlife Service lawenforcement@fws.gov.



Source: Safari Club International (SCI)



Import of Sport-hunted Trophies Subject to Quotas, Tagging and Marking

Background: The U.S. Fish and Wildlife Service (Service) is aware of confusion and miscommunication regarding the import of sport-hunted trophies that are subject to quotas under the Convention on International Trade in Endangered Species of Fauna and Flora (CITES). The Service wishes to remind the trade that under U.S. CITES regulations at 50 CFR Part 23, CITES specimens must be appropriately marked and be accompanied by valid original CITES documents. These CITES regulations, revised in 2007, incorporate CITES resolutions affecting international trade in sport-hunted trophies and are not new requirements. In addition, the special rule for the African elephant under the Endangered Species Act provides for CITES marking requirements. The Service has encountered problems with CITES specimens subject to quotas and marking including leopard, Nile crocodile and African elephant.

Leopard tagging requirements for skins and mounted sport-hunted trophies:
- Each raw or tanned skin must have a self-locking tag inserted through the skin and permanently locked in place using the locking mechanism of the tag. The tag must indicate the country of origin, the number of the specimen in relation to the annual quota, and the calendar year in which the specimen was taken in the wild.
- A mounted sport-hunted trophy must be accompanied by the tag from the skin used to make the mount.

African elephant tusk marking requirements:
- The trophy (tusks) must be legibly marked by means of punch dies including: Country of origin using ISO codes followed by the last two digits of the year of registration and the weight of raw ivory to the nearest kilogram. Any mark must be placed on the lip mark area and indicated by a flash of colour which serves as a background for such mark.

Nile crocodile tagging requirements for skins and mounted sport-hunted trophies:
- Each raw or tanned skin must have a non-reusable tag inserted through the skin and locked in place using the locking mechanism of the tag. The tag must be permanently stamped with the two-letter ISO code for the country of origin, a unique serial number, a standardized species code, and the year of production or harvest.
- A mounted sport-hunted trophy must be accompanied by the tag from the skin used to make the mount.

The tag information or tusk marking as noted above must be recorded on the accompanying CITES document. This information is generally placed in the description block or special conditions block of the CITES document.

In addition, for leopard and African elephant, the number of the specimen to be exported in relation to the current year quota must be shown on the CITES export document (in block 11 of the CITES standardized document). If the specimen was harvested and/or registered in a different year than the year in which it

NOTICE TO THE WILDLIFE IMPORT/EXPORT COMMUNITY
was exported, this information will be different than the information on the CITES tag or tusk marking.

If the permit is issued in a different year than the year of export, this information must reflect the year of export. Export quota information is not required on CITES re-export certificates.

Action: Sport-hunted trophies imported into the United States that do not comply with the marking,
tagging or CITES document requirements are subject to refusal of entry or seizure.

Contact:
U.S. Fish and Wildlife Service
Office of Law Enforcement
703-358-1949; 703-358-2271 (fax)
lawenforcement@fws.gov (e-mail)

 

[BRICKBURN]

In reading this document I can only be flabbergasted by the shear insanity of this requirement for Leopard, etc.

I thought someone misquoted a statement somewhere and it was a mistake. Seeing it in writing.....

Require a metal CITES tag in a Leopard with a year in which it was hunted (removing that Leopard from said years CITES quota amount for said country for that year) then requiring the Quota from the year it is shipped as well.

How in any any rational mind can this make sense?
Two quota allotments for one trophy Leopard.

The Nightmares I can dream up as a result of this:
1. Double the price for Leopard Tags for Americans.
2. More Leopards being shot as a control measure. (Half can't be hunted.)
3. Any delay over a calendar year end and you are screwed. (or out a lot of money)
4. Process a Leopard skin. No more hunting in the 3 to 6 months leading up to year end. Just in case.
5. Fastest taxidermy and shipping process on the planet. Leopards all shipped on their own so there is no delay.
6. No more Leopard Taxidermy in Africa. Dip and Pack only within the time frame required for this.
7. For those in limbo, having already taken a Leopard, I wonder where your trophy will end up? Paying triple shipping if their is s clerical error; money for storage somewhere; abandonment, etc.
8. Lots of Leopards are going to be effectively NON-EXPORTABLE!

All CITES exporting countries would be insane to have an American hunt a Leopard, etc. with this USFWS insanity in place

 

[35bore]

I am still learning here, please bear with me.

What happens to all of the animals that have been seized by the US government? Where do they end up and can the owner EVER re-claim them once they jump through the bueraucratic B.S.????

Brick, you are right just contemplating myself how much this could start a ripple effect with higher prices "for us" or dip and pack being your only option for any game.

I agree that at least they are trying to prevent seizures but, why complicate an already complicated procedure.?.?

 

[tap]

I have been screaming about this issue for a year now. My wifes kzn leopard is in this mess. We haven't shipped it out yet as usfws wont grant an import permit for it. The problem is line 11A. Mainly the pelt tag does not confrorm to usfws paperwork requirements. The tag simply has the leopard cites number on it. USFWS wants the year of kill, the number of permits for that year, and the tag number of that specific quota.

They don't care that a cites permit was issued. All they care about is tha they have a legal loophole in which to seize trophys with.

As of now there appears to be no end in sight and unless SA re-issues my wifes pelt tag in the proper format we will never see her leopard again.

 

[RickB]

I am still learning here, please bear with me.

What happens to all of the animals that have been seized by the US government? Where do they end up and can the owner EVER re-claim them once they jump through the bueraucratic B.S.????

I would bet they will be destroyed?

I have heard of people having problems getting their polar bears into the U.S. as well. People who shot them before they where put on the "not really endangered list" can not bring them into the states. Like brick said any "rational minded" person knows they where taken legally before the ban. One should be allowd to bring it in. But these bunny lovers dont want to hear it!!! Makes me mad!!!!!

 

[RickB]

How in any any rational mind can this make sense?

rational....the government!!!! you should know better!!!! lol
I know what you mean. This is the most rediculous thing I have heard in a long time. Something only a government could come up with.

 

[sestoppelman]

Nothing surprises me anymore!

 

[BRICKBURN]

I have been screaming about this issue for a year now. My wifes kzn leopard is in this mess. We haven't shipped it out yet as usfws wont grant an import permit for it. The problem is line 11A. Mainly the pelt tag does not confrorm to usfws paperwork requirements. The tag simply has the leopard cites number on it. USFWS wants the year of kill, the number of permits for that year, and the tag number of that specific quota.

They don't care that a cites permit was issued. All they care about is tha they have a legal loophole in which to seize trophys with.

As of now there appears to be no end in sight and unless SA re-issues my wifes pelt tag in the proper format we will never see her leopard again.

If it were only remanufacturing another tag with the "proper" numbers on it, I could see how that might be done.

These guys look like they want another CITES tag from the year it is to be shipped on top of that.

 

[Calhoun]

As I've said before the anti's are in the USFWS. They are getting their way - impose more money & more tags to get your trophies into the country will prevent the sane people from hunting them! It's ridiculous and about time our elected officials straighten this bunch of people out. They are paid & work for us!

 

[Jim Rea]

Dear God am I now worried. I am leaving for a Leopard hunt in Namibia April 24th. I have my cites tag already, but now will take a copy of this paper to show my outfitter. Ughh

 

[BRICKBURN]

Dear God am I now worried. I am leaving for a Leopard hunt in Namibia April 24th. I have my cites tag already, but now will take a copy of this paper to show my outfitter. Ughh

Jim what makes me nervous is an Namibian outfitter I was just chatting with:

"its no problem! Cities office is aware of all these US fish and wildlife ****!
Lucky we have a great system in place that is approved by the US!"

Must be they are better connected with USFWS than the guys who are getting their cats confiscated or is unaware about what has really been going on lately.

I'm nervous for you.

 

[Bert the Turtle]

I read it and I can't understand it. That worries me, because it means that I can't be sure I'm compliant. I can't tell exactly what the requirement is if it is shipped in a different year from when it was shot: it says the information will be different on the tag and the form, but it isn't clear to me if that is a problem or if that is what they expect, or what.

 

[35bore]

I read it and I can't understand it. That worries me, because it means that I can't be sure I'm compliant. I can't tell exactly what the requirement is if it is shipped in a different year from when it was shot: it says the information will be different on the tag and the form, but it isn't clear to me if that is a problem or if that is what they expect, or what.

Just re-read it, it looks like they want the year the CITES or year it was harvested and also the year of export. I hope they know if you shoot on in December that it won't come to the states until the following year. Unless they start allowing them in our carry on bag

 

[Bert the Turtle]

If they just want the CITES year and the export year, that should be easy enough: CITES Leopard 27/125 allotted 2013, exported 2014. Perhaps people on the shipping end are not filling in the form properly and that is the problem. If one based his view of the world on extra-governmental experiences, one would think that leaving the "exported" line blank would be easy enough to fix by just filling it in at the destination since it is pretty obvious by looking at the manifest when it was exported. If, however, one has any experience with the government, one would realize that is simply impossible. The people who check the forms are paid to check the forms, not to make decisions. That is frustrating when what you want is some discretion, but it is a benefit when you know the rules. The inflexibility works both ways: they won't help you if they don't want to, but they won't screw you even if they want to if you do things right.

As an example of this concept, my wife and I moved to Florida about 10 years ago. We went to update our drivers licenses. You needed your old drivers license and another form of ID. She gave them her drivers license and her Veteran's Administration ID card. The latter was not acceptable. I pointed out that it was issued by the federal government, had her picture on it, and was clearly a form of ID. I could not convince the man to accept it and we left. It wasn't on his list. It was livid. My wife was not, and simply looked up what the rules were. We went back an hour later with her drivers license and a baby book. It had pictures of her as a baby, grade school, girl scouts and so forth. The guy looked at it for quite a while, very friendly, enjoyed the pictures, we had a nice conversation. My wife then asked for her drivers license. He said that he needed a second form of ID. She said he had it, in the form of the birth announcement contained in the baby book. He said that was ridiculous, which I had to agree with. My wife told him to look up regulation such and such, paragraph so and so, line whatever. He did, found that one of the acceptable forms of secondary ID was a birth announcement in a baby book. He said, sure enough, step right over here for your photo and your new drivers license.

My point is that none of it has to make any sense whatsoever, it just has to follow the rules. So long as the rules are clear and are followed, there is no problem. I always let my wife handle these things because clearly she is a genius at it, but a complete understanding of the rules is critical. A copy of the rules always helps when you are dealing with these people. Understand the rules, follow them to the letter, and there are usually no problems. The people that have trouble don't do it right, and then expect someone to use discretion to help them. The lack of discretion cuts both ways: the person who won't cut you a break because you used navy blue ink instead of black ink also won't capriciously screw you if you do it right.

 

[35bore]

Bert, when dealing with the government I find very little amusement in their way of thinking. I will give you my for instance, When I renewed my CDL (drivers licence) I took of all things my old drivers licence (heaven forbid). I was told that they now need a copy of my birth certificate, REALLY??? Anyway instead of driving 33 miles back home and then another 33 miles back to this point, I walked 2 block, got that 2 blocks, to another government agency and paid $15 for a copy of my birth certificate, they required I show them my ,,,,,,,wait for it,,,,, a Drivers licence. Paid them for the copy, with a chuckle, walked 2 blocks back and got my new drivers licence. Explained what had just happened to the person behind the counter, she did not laugh, she said this is part of the homeland security measure, I said "it is a flawless system"....I have to laugh, because before joining this site, I thought just the US government was this F'ed up, but found this is a world wide epedemic. Get elected into a position to represent the people who put you there, and then you lose your common sense. Sorry for the rant, just have to try and laugh and get on with it.

 

[Bert the Turtle]

That is the perfect example. Of course you get the birth certificate with the drivers license so that you can prove to the drivers license people who you are. When we got our new super secure high tech federal ID badges to prevent whatever it is they were trying to prevent that the old badges couldn't prevent, we had to show our old low tech insecure ID badge to prove we were who we said we were. Pointing out the illogic of this does not help the mission in any way, so it is best to do just what you did, laugh about it and keep it as a funny story.

 

[sestoppelman]

Not too far off of that.. Bank of America now wants everyone to have a debit card (I dont have one and dont want one) to do all transactions in my local (very small branch). So I went in today to draw some money out of savings for car repairs, was asked for the 1000th time for the debit card I dont have, gave my account number and a withdrawl form filled out that comes with your checks and was told all withdrawls are electronic, NO PAPER!, as she is chucking my carefully filled out and signed form in the round file. The teller then proceeded to have me sign another piece of PAPER to authorize the withdrawl. I asked the teller, pointing to the paper I had just signed.."I thought you said no paper", to which she replied "Well, just that one"! Ay yi yi!

 

[Kowas Adventure Safaris]

Dear God am I now worried. I am leaving for a Leopard hunt in Namibia April 24th. I have my cites tag already, but now will take a copy of this paper to show my outfitter. Ughh

My honest recommendation is to bring this issue to the immidiate attention of your Outfitter, which need to inform the local taxidermist as well as shipper without any delay.

With whom are you going to hunt in Namibia?

 

[Jim Rea]

I will be hunting with Orpa Hunting. I plan on emailing a copy of this to him. Hopefully I will have everything complete in the same calendar year. I have received my Cites tag already.

 

[saeng101]

Ezemvelo Wildlife is very helpful in getting correct paperwork out. I would not worry, your PH will get it easily. If you have concerns send me a PM and I will give you the email for the chap in the PM office that deals with this. I just had another member here that he dealt with the export permit after the fact.

I have been screaming about this issue for a year now. My wifes kzn leopard is in this mess. We haven't shipped it out yet as usfws wont grant an import permit for it. The problem is line 11A. Mainly the pelt tag does not confrorm to usfws paperwork requirements. The tag simply has the leopard cites number on it. USFWS wants the year of kill, the number of permits for that year, and the tag number of that specific quota.

They don't care that a cites permit was issued. All they care about is tha they have a legal loophole in which to seize trophys with.

As of now there appears to be no end in sight and unless SA re-issues my wifes pelt tag in the proper format we will never see her leopard again.